Schaeffer v. Putnam, 829 N.W.2d 190 (Iowa Ct. App. 2013)

(plaintiffs brought suit against former attorney for negligence and breach of fiduciary duty by attorney and his LLC established to secure plaintiffs’ loans; plaintiffs contend the breach renders the mortgages unenforceable; defendant brought counterclaim for unpaid legal fees and to foreclose on mortgage; jury found for defendant on negligence claims and court awarded unpaid attorney fees to defendant; in separate proceeding, court ordered in rem judgment in favor of defendant on agricultural property; plaintiffs appealed claiming failure of defendant to obtain mediation release before filing counterclaim seeking to foreclose on agricultural property meant district court lacked jurisdiction to hear counterclaim; appellate court held counterclaim foreclosing on agricultural property required mediation release in accordance with Iowa Code Sec. 654A, so district court lacked subject matter jurisdiction; matter reversed and remanded for dismissal of counterclaim without prejudice).